On Tuesday, December 16, 2025, the Upper House of the Dutch Parliament approved the entire 2026 Tax Plan package. Additionally, the Upper House adopted several motions. We have prepared a summary ...
These judgments are very important for the practice, because the Supreme Court addressed the applicationof the anti-abuse provision in holding structures.
The Act offers a temporary solution until a new Box 3 regime is implemented under the Actual Return on Investment Box 3 Act (probably as of January 1, 2028).
At first glance, the possible solutions, which have been developed together with the tax (legal) practice, seem to be a good approach to solve the bottlenecks.